AS AUTOMATION SYSTEM HELLAS, recognizing the importance of transparency, integrity, and responsible business conduct, adopts this Whistleblowing Policy with the aim of fostering a working environment characterized by trust, fairness, and respect for ethical standards.
The Company encourages the timely and responsible reporting of incidents that may constitute violations of applicable laws or internal procedures, considering that open communication and accountability are fundamental pillars for sustainable development and the protection of all stakeholders.
Within this context, this Policy is implemented in compliance with Directive (EU) 2019/1937 and Law 4990/2022, in particular Articles 1 and 3 thereof, which establish the framework for the protection of persons reporting breaches of Union law.
The purpose of this Policy is to establish an effective mechanism for reporting violations, to enhance transparency, and to protect reporting persons against retaliation, in accordance with Article 17 of Law 4990/2022.
This Policy applies to persons falling within the scope of Article 6 of Law 4990/2022, namely individuals who acquire information on breaches in a work-related context.
Such persons include employees, former employees, job applicants, self-employed individuals, shareholders, members of management bodies, as well as third parties cooperating with the Company, such as suppliers and subcontractors.
Reports may concern breaches falling within the scope of Article 4 of Law 4990/2022 and Article 2 of Directive (EU) 2019/1937, including, but not limited to, areas such as public procurement, financial services, prevention of money laundering, environmental protection, public health, and personal data protection.
In addition, this Policy also covers serious violations of the Company’s internal regulations, provided that such violations relate to the public interest or may cause significant harm to the Company.
Protection is granted provided that the reporting person had reasonable grounds to believe that the information reported was true at the time of submission, in accordance with Article 7 of Law 4990/2022.
The Company has established internal reporting channels in accordance with Article 8 of Law 4990/2022, which are designed and operated in a manner that ensures the confidentiality of the reporting person’s identity, as required by Article 14 of the same law.
Reports may be submitted through the dedicated platform available on the Company’s website (Internal Reporting Submission), either anonymously or by name, in accordance with Article 9 of Law 4990/2022.
Reporting persons also have the right to submit reports externally to the National Transparency Authority, in accordance with Article 12 of Law 4990/2022.
The Company has appointed a Reporting and Monitoring Officer (Whistleblowing Officer) in accordance with Article 8(3) of Law 4990/2022, who is registered in the sepenet.gr system.
The Officer is responsible for receiving, recording, and monitoring reports, acting with independence and impartiality, as provided for in Article 10 of Law 4990/2022.
The handling of reports is carried out in accordance with Article 10 of Law 4990/2022.
In particular, the Company acknowledges receipt of the report within seven (7) days, in accordance with Article 10(2), and provides feedback on the progress of the investigation within a period not exceeding three (3) months, in accordance with Article 10(4).
Investigations are conducted in an objective and impartial manner, ensuring the rights of all parties involved.
In the case of an anonymous report, the obligation to acknowledge receipt and provide feedback on the progress of the investigation applies only to the extent that communication with the reporting person is possible.
The Company ensures the confidentiality of the reporting person’s identity, as well as that of any third party mentioned in the report, in accordance with Article 14 of Law 4990/2022.
The processing of personal data is carried out in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and Article 22 of Law 4990/2022, which specifically governs data processing in the context of whistleblowing reports.
The Company strictly prohibits any form of retaliation against individuals who submit reports, in accordance with Article 17 of Law 4990/2022.
Protected persons are fully safeguarded against actions such as dismissal, demotion, harassment, or any other form of adverse treatment, as provided for in Article 18 of Law 4990/2022.
The protection provided by law does not extend to cases where it is proven that the reporting person knowingly submitted false information, in accordance with Article 23 of Law 4990/2022. In such cases, appropriate sanctions may be imposed.
The Company maintains records of reports in accordance with Article 16 of Law 4990/2022, ensuring confidentiality, integrity, and restricted access to authorized personnel only.
Personal data are retained only for the period necessary and proportionate to the purpose of processing.
